Reprinted from the ACJ - March, 2001
"Hey Boss! Johnny just splashed some of that XYZ Flux in his face. How nasty is it?" The Boss looked up, "It's Monday, he's hungover and unshaven. I'll bet he looks real nasty." "Not his face boss, the flux. He says it's burning a little." "OK calm down, we better check the MSDS book. Get on the other side of the table and lift." "But boss, he's hurting, we don't have time for this." The Boss grimaced," Don't argue. We need to lift the table. It has one short leg and I use the MSDS book to level it out." Standing upright he continued," XYZ Flux...here it is. Let's see...revised August 1943...in case of contact...it says we should...put employee down in as humane a fashion as is possible." "You know, I think I have more recent MSDS update for this flux. Check that file." "This tall cabinet boss?" "No, no, the one next to it." "Sir, that's a garbage can." "I prefer circular file, wise guy, dig down a bit. I'm sure it's in there." "OK boss, here it is...says...wash thoroughly with soap and water." The boss sighed, "Good, that's a relief. Hate to lose a good shop guy on a busy day. Good thing we had the updated version."
If one thing is constant, it's change. Material Safety Data Sheets (MSDS) are designed to reflect the most current health, safety, and first aid information available at the time of printing (just check the disclaimer). But things change. Formulas are altered, new medical procedures are implemented, old ones improved. Material hazards, and our perception of what is hazardous constantly evolves. Since things change, so should our MSDS file.
Manufacturers and distributors must send a MSDS with your first shipment of a new product. We are supposed to keep that one in our files, we all know that. But as the information on a product changes you may receive an updated MSDS on a product you have used for years. Shop owners, managers, and safety people also have a responsibility dealing with this `not so junk' mail. Someone must compare the old MSDS with the new, note the changes and relay them to everyone concerned. Flipping it over to add up the delivery cost and tax on a recent order does not constitute a `review'. If the only change is a new date or maybe they added an e-mail address, replace the old one and move on. But if a hazard, health concern or fist aid procedure has changed, that information must be forwarded to all affected employees. Pass it around or gather folks together and read it out loud. You could highlight the changed areas of the document and post it in the shop for awhile. Knowing that Butch digs through the waste basket as he is emptying it, looking for bad job reviews of his coworkers or old girlie magazines won't satisfy this requirement. Just make sure that everyone knows that euthanizing Johnny is not the current state of the art in emergency first aid.
The new MSDS should replace the old one and be available for worker perusal. Telling the OSHA guy that the landfill is open the same hours as your shop and constitutes `availability during normal working hours' won't cut it. I guess if the table is not too heavy, storing it under one of the legs would satisfy this rule. If you are a distributor of the product, it is your responsibility to forward the new MSDS to your customers just as you did with the original. You did forward the original MSDS, right? Quit laughing and answer the question.
It is a good idea to keep the old copies or write `This MSDS replaces the August 1943 version' on the new one. Visiting inspectors will be impressed with your ongoing Hazard Communications program. Unimpressive is the OSHA guy, head down in the dumpster, leafing through the refuse as you read out loud from the regulations about `the MSDS being available to authorized government representatives upon request'. Keep in compliance by keeping your MSDS current. Keep up the up keep.
The above article was written by David M. Brown, Chief Engineer of Johnson Manufacturing Company, Inc. and is published by JOHNSON with the expressed approval of the National Automotive Radiator Service Association and the Automotive Cooling Journal. Other reproduction or distribution of this information is forbidden without the written consent of JOHNSON and NARSA/ACJ. All rights reserved.
JOHNSON MANUFACTURING COMPANY
114 Lost Grove Road / PO Box 96 / Princeton, Iowa 52768-0096
Phone 563-289-5123 or Fax 563-289-3825